The maximum cell density for a liquid culture is 200 million yeast cells per milliliter
What is this, a culture for ants?!
Seriously though, I'm confused. I've harvested slurries that were >3 billion/mL.
I'm assuming - and we know what that does - that 200cells/mL is the max growth you can get out of the total volume of a starter. Of course if you let it settle the dense cells at the bottom will be much more dense, but they didn't grow at that density.